1. GoBD Update: Structured E-Invoices
Effective July 14, 2025, the Ministry of Finance clarified how structured e-invoices must be archived:
XML is the legal record – Only the XML component of e-invoices, including ZUGFeRD hybrids, must be archived. PDFs are optional if a readable view can be generated.
Archive original format – Invoices must be stored in the format received, even if converted internally, to satisfy audit requirements.
Hybrid formats recognized – For ZUGFeRD or similar, the embedded XML is the tax‑binding element.
Electronic archiving must comply with GoBD, ensuring real‑time access for tax authorities, and data generally must remain in Germany.
2. Retention Period Shortened to Eight Years
In a July 8, 2025 BMF letter, Germany shortened the invoice retention period from 10 to 8 years for invoices whose period had not yet expired by December 31, 2024.
Invoices issued before January 1, 2017 no longer need to be retained, unless still relevant for open tax determination periods (e.g., input tax adjustments under §15a UStG in real estate).
VAT records remain unaffected by this change.
3. New Rule on Unauthorised VAT in Credit Notes
Also from 6 December 6 2024, an unauthorised tax certificate now arises if:
A non‑entrepreneurial person shows VAT in an invoice or credit note, and
The person does not immediately object to the incorrect credit note.
This legislative change overrides the 2019 BFH ruling (V R 23/19), which previously held that credit notes were not subject to §14c(2) UStG in the same way as invoices.